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Supreme Court Rejects Attempt To Expand The Scope Of The Americans With Disabilities Act

Employment Law Development
Dec. 2001

By: Niccolo N. Donzella, Esquire

DEFINING DISABILITY.
An employee is assigned to a work unit that performs four basic manual tasks. She has a physical condition that restricts her from performing one of the unit's tasks, but not the others. She asks to be excused from that task. Does a job-specific physical limitation qualify as a disability under the Americans with Disabilities Act (the "ADA") and entitle her to be excused? The answer, according to a unanimous Supreme Court in Toyota v. Williams (2002), is no. In order to be considered disabled under the ADA, she must have a physical condition that restricts her from performing far more general tasks than those associated with a specific job - she must be limited in the tasks that most people need in their daily lives, like grooming or cleaning. By rejecting the notion of a job-specific disability, the Court prevented employees from using the ADA to pick and choose among available positions, thus greatly reducing the number of people able to claim an ADA disability. THE

FACTS OF THE CASE.
Ella Williams was a Toyota assembly line worker. After developing carpal tunnel and tendinitis, her physician placed her on permanent work restrictions. As a result, Toyota transferred her to its quality control unit, which was responsible for four tasks:
(1) first paint inspection,
(2) second paint inspection,
(3) body inspection, and
(4) repair of surface defects.

For two years, Williams was assigned to perform only the two paint inspection tasks. The first involved a visual paint inspection; the second required her to wipe each car as it passed with a gloved hand. Then Toyota decided to have all employees in the unit rotate through all four tasks.

The body inspection task required Williams to apply a light coat of oil on cars moving through the line and inspect them for dents, scratches, and other defects. But applying the oil required her to extend her arms and wrists at shoulder height, which caused her to experience neck and shoulder pain.

As an accommodation, she asked to be excused from the rotation requirement and to go back to doing only the first and second paint inspection tasks. According to Williams, Toyota refused her request.

According to Toyota, Williams began missing a lot of work. In any case, she was fired. Williams filed suit claiming that she was disabled in the performance of manual tasks and that Toyota had violated the ADA by refusing to change her job assignment.

The trial court dismissed her suit, finding that she was not disabled in the performance of manual tasks, as she could perform two of the work unit's four tasks and could tend to her personal hygiene and carry out personal and household chores.

Williams appealed to the Sixth Circuit, which reversed the trial court, finding that the proper focus was not on what manual tasks Williams could perform generally, but on whether she could do the specific tasks required by the oiled surface inspection. Toyota then appealed to the Supreme Court.

THE ISSUE.
The issue raised by the Sixth Circuit's decision was a fundamental one. Should the focus of a disability determination be limited to what the employee can or cannot do at work, or should it be broader than that, taking into account what he or she can do at home, as well?

THE SUPREME COURT'S DECISION AND WHY IT IS IMPORTANT FOR EMPLOYERS.
In a unanimous decision authored by Justice Sandra Day O'Connor, the Supreme Court reversed the Sixth Circuit, holding that when a court is called upon to determine the existence of a disability under the ADA, "the central inquiry must be whether the claimant is unable to perform the variety of tasks central to most people's daily lives, not whether the claimant is unable to perform the tasks associated with her specific job." Thus, the Court ruled, it was error for the Sixth Circuit to ignore evidence that Williams was able to tend to her personal hygiene and carry out personal and household chores, as these are the kinds of manual tasks that most people need to perform in their daily lives. This decision is very important for employers. As the Court noted, accepting the Sixth Circuit's notion of job-specific disabilities would greatly expand the number of people who could claim disability under the ADA, far more than Congress intended.

When is an employee who performs manual labor considered disabled for purposes of the Americans with Disabilities Act (the "ADA")? Is it when the employee is unable to perform manual tasks that are central to the daily lives of most people, or is it simply when the employee is unable to perform the specific manual tasks needed to perform a specific job. In one of its most important ADA decisions for employers in recent years, a unanimous Supreme Court rejected the latter and held to the former.

Facts of the Case.

The employee in this case was a Kentucky assembly line worker in a Toyota plan, whose duties included working with pneumatic tools. Apparently through use of the tools, she developed carpal tunnel and tendinitis, and her physician placed her on permanent work restrictions precluding her from lifting more than 20 pounds, frequently carrying or lifting things weighing more than 10 pounds, performing overhead work, and engaging in repetitive flexing and bending of her wrists and elbows.

As a result, her employer gave her modified duties, but she nonetheless sued. The parties settled the suit by transferring her to a quality inspection unit, which was responsible for four tasks: (1) first pain inspection, (2) second paint inspection, (3) body inspection, and (4) repair of surface defects.

For two years, the employee was asked only to perform the two paint inspection tasks. The first involved a visual paint inspection, initially with the opening and closing of doors but later without such tasks. The second required her to wipe each car as it passed with a gloved hand. But then, the employer determined to have all employees in the unit rotate through all four tasks. The body inspection task required the employee to apply a light coat of oil on cars moving through the line and inspect them for dents, scratches, and other defects. However, applying the oil required her to expend her arms and wrists at shoulder height, which caused her to experience neck and shoulder pain. As an accommodation, she asked to be excused from the rotation requirement and to go back to doing only the first and second paint inspection tasks.

According to the employee, the employer refused her request.

According to the employer, the employee started missing a great deal of work. In any case, she was fired and she filed suit claiming a violation of the ADA.

The Decisions of the Lower Courts

The trial court dismissed the case after finding that the employee was not disabled within the meaning of the ADA. The trial court's reasoning was that, while she did have a physical condition that limited her ability to perform certain manual tasks, her condition did not substantially limit a "major life activity," as required by the ADA. That is, she seemed to have a physical condition that allowed her to perform two of the inspection unit's responsibilities, but not the rest. The employee appealed this decision to the Sixth Circuit, which agreed with her. The Sixth Circuit determined that an employee is "disabled" when he or she cannot perform "a 'class' of manual activities affecting the ability to perform tasks at work."

The issue raised by the Sixth Circuit's decision was a fundamental one. Should the focus of a disability determination be limited to what the employee can or cannot do at work, or should it be broader than that, taking into account what he or she can do at home, as well? From the perspective of employers, limiting this analysis to work would permit employees to avoid particular work assignments by claiming that they are unable to perform the specific manual tasks needed to do that job, regardless of whether the condition prevented them from doing other jobs at work or tasks at home.

The Supreme Court's Decision and Why It Is Important

In a unanimous decision authored by Justice Sandra Day O'Connor, the Supreme Court reversed the Sixth Circuit, holding that when a court is called upon to determine whether a physical condition that limits the performance of manual tasks constitutes a disability under he ADA, "the central inquiry must be whether the claimant is unable to perform the variety of tasks central to most people's daily lives, not whether the claimant is unable to perform the tasks associated with her specific job." In doing so, the Court noted that this particular employee was able to tend to her personal hygiene and carry out personal and household chores, which indicated that she was not substantially limited with respect to the mkinds of manual tasks that most people need to perform in their daily lives. This decision is important in that it prevents employees from claiming entitlement to accommodation based on a "selective" inability to perform the manual tasks associated with a particular job. To hold otherwise, as the Court noted, would greatly expand the number of people who could claim disability under the ADA, far more, the Court noted, than Congress had ever intended.